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on white paper of a blank Form 872, signed in ballpoint pen by
petitioner and Mrs. Hernandez. Although the Court is not a
handwriting expert, cf. Bagby v. Commissioner, 102 T.C. 596, 606
(1994), the signatures of Mr. and Mrs. Hernandez on the form
appear to be similar, indeed virtually identical, to their
signatures on the first extension of the period of limitations
and their signatures on the Forms 1040 they filed for each of the
years in issue. Furthermore, petitioner’s insistence that the
March 20, 1995, Form 872 was printed on green paper may be easily
explained by the fact that he and Mrs. Hernandez signed the first
extension, for tax year 1990, which was printed on green paper,
and that he incorrectly recollects that extension as the second
Form 872 signed by petitioner and Mrs. Hernandez on March 20,
1995, which is on white paper.
Petitioner has produced no evidence to show that the Form
872 dated March 20, 1995, was altered in any way or that the
signatures on the form were not those of him and Mrs. Hernandez.
Petitioner has neither carried his burden of proof by going
forward with evidence that this Form 872 is a forgery, nor has he
carried his burden of ultimate persuasion. Rule 142(a); see also
Bybee v. Commissioner, T.C. Memo. 1996-411, affd. without
published opinion 129 F.3d 124 (9th Cir. 1997) (taxpayer failed
to show that signatures on Form 872 were forgeries). We find
that the Form 872 dated March 20, 1995, is a valid extension,
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